IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1 - Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Policy and Management System
At the corporate level, the company has policies on Health, Safety, Environment (HSE), social, sustainability, ethics, inclusion and diversity, demonstrating its commitment to safe working environment, injury and illness prevention, reducing environmental pollution, and ensuring compliance with statutory and regulatory requirements. These policies align with IFC PS requirements and apply to all Qair’s projects, including the El-Khobna project. They will be shared with all project personnels, including contractors. Therefore, CSK is not expected to develop its own policies but adopt Qair’s and, where needed, develop project-specific procedures and plans.
As per ESAP#1, Qair/CSK will develop and implement a project-level HSE management plan detailing processes and standards for construction, ensuring adequate E&S management and supervision. It will require the EPC and O&M contractors to implement a project-specific EHS/OHS management system and ESMPs in line with IFC PSs, WBG EHS Guidelines, Qair corporate policies, and ESIA provisions. Qair/CSK has developed procurement and contractor/supply chain management procedures setting minimum requirements to integrate E&S obligations into contracts. These requirements, aligned with IFC PSs and the Contractor Management Guidance Note, have been included in all RFPs and the draft EPC contract. The company also has a code of conduct and sustainability requirements, which is enclosed to EPC and supplier’s contracts.
Identification of Risks & Impacts
The company developed an ESIA in accordance with local legislation, IFC PSs and WBG EHS provisions and guidelines, and good industry international practice. The ESIA assessed all relevant baseline conditions (e. g. air quality, noise, traffic, biodiversity, etc.), analysis of alternatives, climate change risk assessment, cumulative impacts along with relevant mitigating measures and expected residual impacts once mitigants are implemented, and a framework ESMP.
The ESIA also included the baseline condition and impact assessment along the alignment of the OHTL. Qair also assessed the socio-economic baseline of the project and undertook a land tenure assessment. The study also included a critical habitat assessment to determine presence of critical habitat features for the project site and along OHTL alignment. Presence of cultural heritage within the project area of influence was also assessed.
Management Programs
As part of the ESIA study, a framework ESMP has been developed, which provides a summary of the E&S management plans, monitoring requirements and mitigation measures applicable to the construction and operation phases of the project. As per ESAP#2, the EPC and O&M contractors will develop a Construction Environmental and Social Management Plan (“CESMP”) and Operation Environmental and Social Management Plan (“OESMP”). The CESMP and the OESMP will be based upon the ESIA framework ESMP, the project-level HSE management plan, Qair’s E&S policies and IFC PSs requirements. The latter plans will be reviewed and approved by the Lenders prior to use. Construction and operations phase E&S management and monitoring responsibilities will be shared between the company and EPC/O&M contractors, who will be contractually bound to fulfill their ESMP commitments.
The CESMP will comprise a series of sub-plans, including but not limited to: waste management; pollution prevention (covering emissions, spill response, etc.); water management (covering supply, treatment, disposal, etc.); stormwater management, hazardous materials; occupational health and safety; emergency preparedness and response; community health, safety, and security; transportation safety and traffic management plan; accommodation management; local recruitment and labor management; influx management; environmental monitoring plan; stakeholder engagement (including grievance handling); contractor management plans; gender-based violence and sexual harassment, and biodiversity management plans. As for the OESMP, it will consist of a suite of sub-plans, which will include but not be limited to: waste management; pollution prevention (including emissions, spill response, etc.); water management; hazardous materials; emergency preparedness and response; community health, safety and security; road safety and traffic management; biodiversity management including reptiles and pest management; environmental monitoring plan and stakeholder engagement (including grievance management).
With respect to the 45 km greenfield OHTL, construction works are expected to be carried out by Qair’s EPC, while operation will be under the control of STEG. As per ESAP#3, the project will establish an E&S agreement with STEG to allow appropriate access to the OHTL and RoW, aimed at achieving implementation of OESMP, mainly related measures for livelihood restoration and biodiversity monitoring.
The agreement will detail the type and frequency of the interventions and the proposed steps the project will take to ensure STEG and its selected contractors and subcontractors comply with relevant PSs standards and WBG General and sector specific EHS guidelines.
Organizational Capacity & Competency
The company has at a corporate level an E&S Head, based at its headquarters, that has overall responsibility for the project’s ESHS and OHS management. The E&S head also acts as the Africa regional E&S coordinator. The company has recruited local E&S consultants to undertake the ESIA and related studies.
As per ESAP#4, CSK will recruit a country level E&S/EHS manager and a dedicated local Community Liaison Officer for the project. The EPC and O&M contractors will be required to have qualified personnel to oversee all E&S issues including an EHS manager, and EHS/OHS officers based on the size of the workforce.
As per ESAP#1, the company will finalize the project related EHS organogram for both CSK and the selected EPC and O&M contractors before start of construction. These individuals must have sufficient authority and resources to fulfil their responsibilities as required by the project ESMS, IFC requirements, the ESAP, and local regulation.
Emergency Preparedness & Response
The main EPC has developed an Emergency Preparedness and Response (“EPR”) procedure template that sets out minimum requirements and guidelines for the identification and response to possible emergency situations. As per ESAP#2, Qair/CSK and the EPC and O&M contractors will develop a project specific EPR plans in accordance with IFC PS1 and PS4 provisions.
This plan will cover preparedness and responses to a range of potential emergency scenarios including but not limited to: medical emergencies (including on-site injuries, pandemic type outbreaks, snakes and scorpion bites); fire, extreme weather conditions such heatwaves and floods; transport incidents and major hydrocarbon spills. Security related incidents, acts of sabotage/vandalism, terrorism etc. will be addressed with a separate Security Management Plan (ESAP#10 see below). The response plan will include a communication protocol to alert local authorities, communities as appropriate, as well as the management team in addition to specific responses and evacuation procedures. Regular drills and emergency training and exercises will be developed according to IFC PS requirements and conducted by the EPC contractor covering the different emergency scenarios.
Monitoring & Review
The company will be responsible for reviewing and formally auditing their contractors with regards to their HSE performance and compliance against project standards, national requirements and IFC PSs. As part of its project level HSE management plan (ESAP#1), Qair/CSK will establish specific procedures, and allocate resources to monitor and measure the effectiveness of their and their contractor’s management plans / programs as well as compliance with relevant Tunisian legal requirements. E&S / OHS monitoring requirements of the EPC contractor for their own activities and that of their subcontractors will be defined within their management plans (ESAP#2) and approved by Qair/CSK. The implementation will be closely followed by the company during construction activities.
The project-level HSE management plan will also outline the minimum monthly reporting requirements of the EPC contractor. These reports will include coverage of the contractor’s E&S / OHS performance in accordance with reporting requirements outlined within the project ESIA, ESMPs and IFC PS requirements. Clear Key Performance Indicators (“KPIs”) will be developed as part of the reporting.
PS2 – Labor & Working Conditions
The project is expected to employ approximately 450 workers, of whom 100 would be skilled and 350 unskilled, during the peak construction phase. During the Operation and Maintenance (“O&M”) phase, the plant will be operated by CSK, and likely to employ around 45 employees working in shifts. A few expatriates may be retained for oversight and specialized construction. Given strong expectations for local jobs, Qair and the EPC will coordinate with local authorities to maximize and fairly manage community recruitment.
Human Resources (HR) Policies and Procedures
Qair maintains group-level policies such as Ethics Guide and the Group Code of Conduct. The code of conduct also enforces Human Rights commitments that reject child and forced labor, discrimination, harassment, abuse, or violence, while promoting equal opportunities. These policies apply to all Qair’s subsidiaries, contractors, and workers, and will be implemented for this project.
As per ESAP#5, and guided by its corporate standards, host nation law, and PS2, Qair/CSK will prepare for both construction and operations phases a project-specific HR manual. The manual will include (i) Labor Policy statements addressing non-discrimination, equal opportunity, prevention of child and forced labor, freedom of association, and prevention of Gender-Based Violence and Sexual Harassment (“GBVSH”); (ii) HR procedures, including local recruitment, with measures to promote gender equality; worker induction; terms and conditions of employment; disciplinary actions (including GBVSH-related); and workforce demobilization post-construction; (iii) Workers’ Code of Conduct emphasizing respectful behavior in host communities and zero-tolerance for GBVSH; and (iv) Labor Grievance Mechanism (including contractors and third-party workers) enabling receipt and resolution of optionally anonymous grievances, including a separate gender-related issues like GBVSH and discrimination, handled sensitively and confidentially. These HR policies, procedures, Code of Conduct, and Grievance Mechanism will apply to all project workers, including those employed by contractors and sub-contractors (e.g., security providers), and will be translated into French and Arabic (or as relevant), easily accessible, and clearly communicated during induction and through sensitization and training.
No workers’ accommodation camp will be set up during the construction phase as the project intends to hire from the surrounding communities. If needed, workers will be accommodated in the surrounding villages. As part of its project-level HSE management plan (ESAP#1), Qair/CSK will develop an overarching Accommodation Management Procedure that will articulate the minimum requirements for workers accommodation including provision of basic services and welfare facilities, consistent with PS2 requirements and the IFC/EBRD guidance note on Workers Accommodation: Process and Standards. These provisions will guide, if necessary, the development of a project specific accommodation management plan by the company or its contractors or subcontractors (ESAP#2) should workers be accommodated in the surrounding villages. Qair/CSK will require its EPC to develop a transportation management plan including assessing and addressing the risks associated with transporting workers to and from the worksite (ESAP#9).
Working Conditions and Term of Employment
The project will ensure that all employment contracts comply with Tunisian labor codes and IFC PS2 requirements. Every employee (including those hired by contractors and subcontractors) will receive a contract in French/Arabic specifying terms of employment, working conditions (including health and safety standards), wages and benefits, working hours, overtime arrangements and compensation, annual and sick leave, vacation, holidays, and other statutory leaves. Contracts for construction-phase workers will clearly state the short-term nature of the project and indicate the expected employment duration. As per ESAP#6, Qair/CSK will implement strict monitoring requirements, including third-party audits during both construction and operations, to ensure contractors and subcontractors maintain compliance with national laws, employer labor standards, and PS2 provisions. The monitoring frequency will be quarterly throughout the first year of the construction phase and will be adjusted thereafter based on the assessed level of risk.
Occupational Health and Safety (OHS)
Key OHS risks for the project include slips and falls, hazards from moving machinery on-site, heavy lifting, traffic accidents, exposure to electric shocks and burns, bites from venomous snakes and scorpions and safety concerns during panel module assembly. Qair has developed a template HSE construction management plan which covers various mentioned aspects, such as: roles and responsibilities; Safe working procedures such as work at height; PPE requirements; OHS signage standards; medical support provisions; access protocols; induction and refresher training; incident reporting and investigation; and performance monitoring. As part of ESAP#1, Qair/CSK will put in place similar requirements within the project-specific HSE management plan as part of an OHS plan. The OHS plan will further include provisions to manage project-specific risks such as presence of venomous reptiles and high outdoor temperatures and further ensure these are included in the CESMPs and OESMPS (ESAP#2). Qair has developed a risk register which applies to all its operations and includes PV power plants for operation phase. The risk register identifies risk related to intervention on a PV plant and related mitigating action. The risk register will be updated with project specific risk and included in the OHS plan (ESAP#2).
EPC and O&M contractors will also be contractually obligated to deploy an adequate number of qualified Health and Safety (“H&S”) supervisors to ensure compliance with contractual OHS provisions. A H&S Committee comprising worker representatives will be established to provide feedback and recommendations on safety matters, in line with Tunisian regulations.
Labor risk within the supply chain
Qair assesses its suppliers through a structured process that begins during pre-qualification and tendering. Suppliers are screened for environmental and social risks, labor standards, and compliance with Qair’s Code of Conduct and Sustainability Requirements. Contracts include clauses on child and forced labor, gender-based violence, and health and safety, and suppliers must cascade these obligations throughout their supply chains. High-risk suppliers are identified using internal tools and undergo due diligence to evaluate their capacity to mitigate labor risks. Monitoring is conducted during production and testing, often with external auditors, and non-compliance can lead to disqualification or contract termination.
Additionally, Qair requires full traceability of photovoltaic module components, including cells, wafers, ingots, and polysilicon, with third-party verification when necessary. While Qair maps its supply chain up to Tier 1 suppliers, traceability obligations extend to Tier 2 through contractual requirements. Audits are conducted by certified bodies, and Qair reserves the right to terminate contracts in case of breaches. As per ESAP#7, Qair/CSK will engage an independent, reputable and experienced third-party consultant, to conduct an audit of its solar supply chain. This audit will be undertaken to verify labor and working conditions’ compliance with the local regulations and international best practices. The audit report and any suggested corrective actions will be made available to IFC.
PS3 – Resource Efficiency & Pollution Prevention
Resource Efficiency – Greenhouse Gases
Greenhouse gas emissions during construction are expected to be minimal, mainly from fuel use in generators, transport, on-site equipment, and machinery. Although quantities have not been calculated, they are expected to be low and well below 25,000 tCO2eq/year. However, the Project is expected to result in about 225,000 tCO2eq/year GHG emission avoidance.
Resource Efficiency – Water Consumption & Availability
Estimated water requirements are 6,900m³ during construction and 2200 m³/year during operations. Water during construction will mainly be for dust suppression, concrete production, minor batching for substation, control and admin buildings, and domestic use. Consumption will be accurately quantified once key elements (e.g., batching, worker accommodations) are defined. During O&M, water use will focus on panel cleaning, prioritizing dry brush-cleaning. Wet cleaning may be needed when dust adheres due to rain or humidity, estimated at no more than four times per year. Qair/CSK will consider water conservation when selecting efficient cleaning technology and refine the regime to avoid unnecessary use. Due to high salinity in underground water, the project will be sourced by trucks water from the nearest municipality, within a 5 km radius from the site.
Pollution Prevention
During construction, minor and insignificant pollution to air, water, and soil, and increased noise levels are anticipated; these can be mitigated through standard pollution prevention measures outlined in the different environmental management plans. Wastewater will be collected in impermeable tanks and transported by a licensed contractor to the nearest municipal treatment plant. During operations, no significant pollution impacts are expected except wastewater from panel cleaning and regular household waste.
The project will generate non-hazardous waste (paper, wood, plastic, scrap metals, glass) and limited hazardous waste (transformer oils, paints, batteries, electronic waste). Overall volumes during both phases are expected to be low. As per ESAP#2 and #1, CSK and EPC/O&M contractors will develop a waste management plan aligned with local laws, IFC PS3, and WBG EHS provisions. The plan will commit to waste reduction, maximize reuse/recycling, and outline processes for storage, segregation, tracking, transport, and disposal/treatment. It will include full waste traceability, third-party selection criteria, management of broken/expired PV panels, hazardous storage requirements, disposal solutions per good international practices, and ensure hazardous waste contractors are licensed. The company will develop a waste inventory and assess disposal/treatment facilities.
Pollution Prevention – Hazardous Materials
Hazardous materials during construction and operation include hydrocarbons, oils, lubricants, and paints. Leaks from contractors’ vehicles and equipment may affect soil/subsoil. An impermeable storage area with restricted access will be established onsite as required by local legislation. A project-specific hazardous material and spill prevention management plan is developed for both phases by the EPC and O&M, based on the existing corporate hazardous material management policy (ESAP#2). The plan will cover transport, storage, refueling, emergency response, community awareness, training, inspections, maintenance, monitoring, reporting and compliance with national legislation and align with IFC PS3 and WBG EHS Guidelines.
Stormwater management
A hydrology study was conducted as part of the project design, identifying natural stormwater flow during rainy seasons within the project site. Although the risk of flooding was classified as low, installation of stormwater drains was proposed by the hydrology assessment. Furthermore, as part of ESAP#2, Qair/CSK, along EPC contractor and O&M team will develop a Stormwater Management Plan for both the construction and operational phases. The construction-phase plan will include the design of appropriate stormwater drainage systems tailored to the site’s conditions.
PS4 – Community Health, Safety & Security
Community Exposure to Disease
The project is located in a sparely populated rural area, with the nearest residential area Mezzouna, located approximately 3km from the site. Although, the project intends to maximize recruitment from local communities to the extent possible, the large construction related workforce needs may lead to an influx of workers into the region. As stated earlier, no workers’ accommodation camp will be set up for the construction phase.
As per ESAP#8, the project will develop and implement a Community Health and Safety and Worker Influx Plan. The plan will include an assessment of worker influx at a cumulative level given other development projects within the area and will include: (i) a communicable disease (including HIV/AIDS and sexually transmitted infections) awareness and prevention program for site workers as well as local communities; (ii) requirements for adequate on-site medical facilities; (iii) a community grievance mechanism (“CGM”); and (iv) provisions for periodical monitoring of social related effects of the influx of migrants. The implementation of this plan, together with the project Code of Conduct, measures to maximize local recruitment in the local procurement and employment procedure and plan, and the Worker Accommodation Plan (if needed, as per ESAP#2), will help manage the risks and impacts of population influx.
Road Safety & Traffic Management
During construction, the dominant vehicle movement patterns will be in relation to the transportation of construction material and equipment over the 18-months construction period. Increases in traffic related to the transportation of project components may represent a safety risk for the other road users and communities adjacent to the roads being used.
As per ESAP#9, Qair/CSK shall undertake a Transportation and Traffic Risk Assessment and guided by the findings, develop a Project Traffic and Transport Management Plan. The plan will define transport routes to be used for equipment deliveries based on the risk assessments undertaken to evaluate road traffic and conditions with the aim of minimizing impacts. It will also define a safety inspection program for the project (especially for local subcontractors) and implement ongoing monitoring of vehicles and proper use of safety measures.
The new 45 km OHTL will cross above the existing railway nearer to the Meknassy substation. The railway is used for commercial transportation of phosphate and in accordance with STEG requirement a minimum height of 12m will be maintained. Furthermore, the OHTL will cross several untarred tracks. The Transportation and Traffic risk assessment will include the risk assessment of these various crossings. Furthermore, safety risk related to the railway and road crossing during construction will be covered under the OHS management plan (ESAP#2).
Security Personnel
A permanent fence will be erected around the perimeter of the site. Security and access control to the site will be provided on a 24-hour basis by a third-party security company retained by the EPC and O&M contractors during construction and operations. Security guards will not be armed. Per ESAP#10, the project will develop a Security Risk Assessment and Security Management Plan for construction and operations phases based on HSE procedures, assessment findings, and PS4 requirements, including IFC’s “Good Practice Handbook” and Voluntary Principles on Security and Human Rights. The plan will ensure security procedures are communicated to communities to foster understanding and minimize conflicts. During construction and operations. CSK will conduct regular audits of security provisions as part of monitoring and reporting under PS1 (per ESAP#1).
PS5: Land Acquisition and Involuntary Resettlement
The project will be established on a 267 hectares plot that falls under the state’s domain. Qair/CSK will lease the plot for a period of 25 years from the Government of Tunisia. The plot is uninhabited; however, a few structures found on the project land are used as temporary shelters by two herders from the nearby village. The project plot is also used for herding activities mainly by the two identified herders on a seasonal basis and loss of access to grazing areas within the plot is expected. Qair/CSK has developed a draft Livelihood Restoration Plan (LRP), and as part of ESAP#11, Qair/CSK will finalize the project site LRP and implement it in accordance with IFC PS 5 requirements to address the loss of the temporary shelters and grazing areas.
For the 45 km 225kV OHTL, as per the laws in Tunisia, a permanent RoW of 14m on either side, with associated land use restrictions will be established. Based on the current routing of the OHTL, the RoW will pass through state land, requisitioned land and private land impacting around 132 parcels mainly 79 privately titled parcels, 19 requisitioned parcels, and 32 state-owned parcels. No structures have been identified on the RoW; therefore, physical displacement is not expected. Parts of the RoW are being used for agriculture including olive groves and some seasonal livestock grazing. The land use restrictions along the RoW are expected to lead to economic displacement.
The access track of 1 km to connect to an existing track will also be subject to land acquisition. It has been estimated that around 0.6 ha of land areas will be required for the access track. The access track falls under the state’s domain. No structures have been identified on the plot for the access track; hence no physical displacement is expected. Qair has developed a Livelihood Restoration Policy Framework (LRPF) defining Qair’s approach, principles and objectives towards economic displacement, including provisions for a grievance mechanism and vulnerable groups. Based on detailed socio-economic and inventory survey, an OHTL LRP (ESAP #11) will be developed and implemented in accordance with the requirements of PS5 to address economic displacement for the OHTL and the access track following the principles set under the LRPF. As part of ESAP#12, Qair/CSK will recruit an independent consultant, approved by lender; to undertake a completion audit after the full implementation of the LRPs.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project site is in the “Saharan Halophytic Ecoregion” (WWF) and located on a very gently sloping area (less than 3%) bordering a northeast/southwest-oriented mountain range. It is characterized by a low topography, with elevations not exceeding 100 meters. The landscape is characterized by sparse vegetation, composed of species adapted to conditions of water stress and sometimes high salinity. Other existing infrastructure in the vicinity includes several access tracks, an existing overhead transmission line, agricultural activities, and another PV plant nearing construction completion, immediately adjacent. The project will connect to the grid via a new 45 km long overhead 225kV powerline northwards. In its’ southern sections, the OHTL will run adjacent to an existing OHTL until the national park boundary where it will divert eastwards to avoid the park. The alignment of the OHTL is not fully final, but any remaining adjustments are expected to be minimal and have no significant consequence for the ESIA findings.
The PV site is not located within any internationally recognized or Protected Areas but is close to two such areas. The Sebkhet Noual, a wetland of international importance (Ramsar, KBA, IBA) is located ~4 km north-east of the PV site and ~1 km east of the central section of the OHTL line. It constitutes a major ecological sensitivity, particularly for migratory avifauna (including Greater Flamingo Phoenicopterus roseus)when it holds water. The Bouhedma National Park (KBA, IBA) lies ~14km north of the PV site and immediately west of the northern section of the OHTL; around 20m from the buffer zone. This park is home to steppe habitats and associated protected species and qualified as an IBA as a result of ‘bioregion restricted assemblages’, although none of the qualifying bird species are threatened species.
Tunisia has 42 Ramsar sites, many of which have dried out significantly in recent years as a result of climate change (the Mediterranean region has been designated a climate change hotspot), and do not typically perform the ecological function for which they were originally declared. No long term data on the hydrology or avifauna of these sites exists. This is the case with the Ramsar site close to this project. Local ornithological experts believe that these sites now hold water extremely seldom and they are no longer significant avifaunal receptors.
Flora surveys in May 2025, and satellite imagery identify the vegetation of the site as typically steppe, with very sparse plant cover and an unremarkable floristic diversity. The site is characterized by species adapted to dry and sandy conditions. No IUCN threatened plant species were recorded. Two species classified as threatened by the Tunisian Red List are protected: Acacia tortilis (IUCN - LC, National - VU), and Searsia tripartita (IUCN - LC, National - VU). These are both most likely to occur in the mountainous areas along the OHTL. One plant species, Stipa tenacissima (a Needle Grass) is included on the IUCN Red List as Vulnerable (National - LC).
Faunal surveys in May 2025 recorded no threatened or protected species, whilst literature review also recorded no threatened species likely to occur on site. Although not threatened species, several poisonous snakes and scorpions exist in the area, including the highly venomous Yellow Fat-tailed Scorpion Androctonus australis. This poses a risk to construction and operational workers and to the animals themselves through persecution as a result of fear. A protocol will be prepared for the safe management (capture and local relocation) of these animals when encountered, and training and awareness will be conducted for all staff.
Avifaunal surveys have been conducted covering multiple seasons and including transects and vantage points on both the PV site and OHTL. On the PV site, 26 bird species were recorded including no IUCN threatened species and two nationally threatened species: Lanner Falcon (Falco biarmicus, National - EN); and Short-toed Snake Eagle (Circaetus gallicus, National - CR). On the OHTL alignment, 81 bird species were recorded, including several nationally Red Listed species and two IUCN listed: Pallid Harrier (Circus macrourus, IUCN - NT) and European Turtle Dove (Streptopelia turtur, IUCN - VU). A Lanner Falcon nest was recorded on the existing OHTL. No evidence of migration routes was identified from baseline data on site or literature sources. The national Red List for birds does not fully comply with IUCN standards and criteria.
The vegetation on site is classified as modified habitat, with land used to date being primarily grazing by livestock. A standalone Critical Habitat Assessment (CHA) was conducted by an experienced international expert and concluded that Critical Habitat is not triggered for any species, although several Priority Biodiversity Features (PBF) are identified. The PBF include 1 plant, 2 bats, 13 birds and a gazelle. The three of these most relevant to the project (and recorded on site) are: Lanner Falcon; Short-toed Snake Eagle and European Turtle Dove. These are all IUCN Least Concern species.
Biodiversity baseline survey work and reporting is not yet final as some further seasonal surveys are to be done. The results of these surveys are considered unlikely to alter the findings of the ESIA or mitigation and management measures already recommended.
The ESIA has adequately assessed the impact of the proposed project on the identified receptors. A standalone BMP has been compiled by a suitably experienced international expert. The BMP includes the requirement for the installation of Bird Flight Diverters on the full length of the OHTL, including nocturnal devices in the vicinity of the Ramsar site, in line with GIIP (ESAP#13). The BMP also details the Post Construction Fatality Monitoring (PCFM) which will be conducted at the OHTL for at least the first three years of operations, in line with the IFC-KfW-EBRD PCFM Handbook (ESAP #14). During operations, chance find procedures will be used to capture data on any incidental mortality of birds and other wildlife at the PV facility.
PS8: Cultural Heritage
Within the perimeter of the solar PV plant, no archaeological sites were identified, aside from a few isolated ceramic shards with no significant archaeological context. An archaeological site dating from Roman era was identified along the initial alignment of the OHTL. Consultations were carried out with the “Institut National du Patrimoine” (INP) of Tunisa, who recommended a buffer of 400m from the identified site. The project has however moved the line 1 km from the site to avoid any disturbance. The archaeological site is not known to be visited or used by any community members and has not been formally documented by INP. Given the proximity of this site to project activities, particularly truck movement during construction, there is a potential risk of damage. To mitigate this, Qair/CSK will develop a Cultural Heritage Site Management Plan that will include avoidance protocols, in-situ preservation of known sites, monitoring procedures, contractor management measures (ESAP#15). Additionally, Qair/CSK will implement a Chance Find Procedure, ensuring that contractors and employees are trained and sensitized to follow proper protocols in the event of discovering archaeological resources during land clearance or mechanical excavation.
In line with the framework Stakeholder Engagement Plan (SEP), Qair/CSK will ensure that nearby communities are informed about the measures taken to protect cultural heritage within the project’s area of influence.
